COVID and U.S. sanctions

On December 8, 2021, KEI wrote a letter to the Biden Administration, asking for measures to better clarify and simplify its sanctions programs so that the humanitarian exceptions work better. Our interest in this issue was stimulated by the work we have been doing on access to COVID vaccines and therapies, but the issues are much broader.

The letter was addressed to Brian Nelson, the newly confirmed head of the Department of Treasury’s Office of Terrorism and Financial Intelligence, which among other things, oversees the Office of Foreign Assets Control (OFAC), and was copied to several other agency heads.

The US. sanctions are an often overlooked area of U.S. power, and they have a large and negative impact on access to health care technologies. Humanitarian exceptions exist, but are complicated, and many risk averse actors, from health NGOs, commercial suppliers of medical technologies, financial institutions and others avoid dealing with countries that are the subject of sanctions. Five of the heavily sanctioned countries, Cuba, Iran, Syria, Venezuela and North Korea, have a combined population of 167 million persons, and (excluding China) 707 million persons live in 21 other countries subject to U.S. sanctions.

The measures that KEI highlighted are those that others more experienced in sanctions issues have often highlighted in the past, and include the following:

• Create a web page relating to health care products, with plain language guidance that clarifies the scope of sanctions that…